05000382/FIN-2013005-02
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Finding | |
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| Title | Protective Action Recommendations Under Conditions of Changing Wind Vectors Not Consistent with Federal Guidance |
| Description | The inspectors identified an unresolved item related to the adequacy of the licensees guidelines for the choice of protective actions during an emergency in accordance with the requirements of 10 CFR 50.47(b)(10). Specifically, the licensees implementation of guidelines for extending existing protective action recommendations into additional geographical areas of the emergency planning zone under conditions of changing wind vectors may not be consistent with the guidance of EPA-400-R-92-001, Manual of Protective Action Guides and Protective Actions for Nuclear Incidents. The inspectors observed during the December 4, 2013, evaluated exercise that the licensee expanded an existing protective action recommendation for the public into a geographical area for which protective actions may not have been warranted. Specifically, with an existing recommendation of evacuate all sectors within two miles of the reactor and to five miles in three downwind sectors, the licensee subsequently expanded the five-mile recommendation to an adjacent (fourth) downwind sector following a wind vector change. The licensee applied deterministic, plant-condition based criterion in expanding the five-mile evacuation recommendation. The expansion of the protective action recommendation into a fourth sector may not have been warranted because the licensee had valid dose assessments showing that protective action guides were not exceeded at two miles in the newly-affected sector at the time when wind direction changed. The licensee did not apply those results in making the decision to expand protective action recommendations. The inspectors concluded the licensees recommendation was not based on EPA guidance, which states, in part, that protective action guides are the approximate levels at which protective measures are justified, and that evacuation is seldom warranted at less than 1 rem Total Effective Dose Equivalent. The inspectors identified that Procedure EP-002-052, Protective Action Guidelines, Revision 23, allows the licensee to generate evacuation protective action recommendations for members of the general public in areas of the emergency planning zone where radiological protective action guides are not exceeded. The procedure required the user determine the plant is in a stable condition before allowing the application of radiological assessment results when wind vectors change. Specifically, Step 5.4.1.1(A) required as a precondition that plant conditions are well understood and changes can be reasonably predicted, and Step (B) that radiological releases have a high degree of predictability in terms of isotopic composition...and release rate. The inspectors observed that licensee staff understood Step (A) to require that core damage had been arrested and that plant conditions precluded any future change in core state with a high degree of confidence. The inspectors observed that licensee staff used deterministic plant-based protective action recommendations instead of radiological based assessments in expanding protective action recommendations because core damage had not been arrested and future changes in core state were not precluded with a high degree of confidence. In addition, licensee staff also concluded that future release rates were not predictable. This issue was identified as an unresolved item because the NRC has not determined whether the licensee has adequately implemented Planning Standard 10 CFR 50.47(b)(10), which states, in part, that ...guidelines for the choice of protective actions, consistent with Federal Guidance, are developed and in place.... Specifically, the NRC has not determined whether the restrictions on the application of radiological assessments in Procedure EP-002-052, Revision 23, Step 5.4.1.1, adequately implement the guidance of EPA-400-R-92-001. No additional information is required from the licensee. The licensee has entered this issue into their corrective action program as Condition Report CR-WF3-2013-5900. This issue is identified as URI 05000382/2013005-02, Protective Action Recommendations Under Conditions of Changing Wind Vectors Not Consistent with Federal Guidance. |
| Site: | Waterford  |
|---|---|
| Report | IR 05000382/2013005 Section 1EP1 |
| Date counted | Dec 31, 2013 (2013Q4) |
| Type: | URI: |
| cornerstone | Emergency Prep |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71114.01 |
| Inspectors (proximate) | A Fairbanks C Cowdrey C Speer G Guerra G Werner I Anchondo J Beavers J Braisted J Laughlin M Davis S Hedgerj O'Donnelll Carson M Davis P Jayroe R Latta S Hedger C Speer D You F Ramirez G Guerra G Werner I Anchando J Melfi |
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Finding - Waterford - IR 05000382/2013005 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Waterford) @ 2013Q4
Self-Identified List (Waterford)
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